1. Who we are
This website is operated by Vigil8 Partners Limited, a company registered in England and Wales (company number 11707677), with its registered office at 10 Clintons Green, Bracknell, Berkshire, RG42 1YL. Our VAT number is 311633345.
We are the controller of the personal data described in this policy, which means we decide how and why it is used. References to "we", "us" and "our" mean Vigil8 Partners Limited.
ICO registration number: ZC276745
2. How to contact us
Our Data Protection Officer is Craig McLean. For any question about this policy or your personal data, contact us at:
- Email: privacy@vigil8.com
- Phone: 020 3126 4925
- Post: Data Protection Officer, Vigil8 Partners Limited, 10 Clintons Green, Bracknell, Berkshire, RG42 1YL
3. The personal data we collect
We only collect personal data that you choose to give us, or that we need to do business with you. This includes:
- Enquiry details you submit through our contact form, by email or by phone: your name, work email address, organisation, the outcome you are interested in and any message you send us.
- Business contact details of people at our clients, prospective clients, partners and suppliers, such as name, job title, work email and phone number.
- Correspondence between you and us.
We do not intentionally collect special category data (such as health information) through this website. Please do not include it in your message.
Website analytics: we use Google Analytics, a service provided by Google Ireland Limited, to understand how visitors use our website. It tells us things such as which pages are visited, how long visits last, what type of device and browser is used, and the approximate location (town or country) visitors come from. We use this only in aggregate, to improve the website. Google Analytics does not tell us who you are, and it does not log or store your IP address.
Cookies: Google Analytics uses cookies. We only set them if you accept analytics cookies in the cookie banner, and you can change your choice at any time through the cookie settings on this website or in your browser. The website also sets cookies that are strictly necessary for it to work, such as the cookie that remembers your cookie choice. We do not use advertising cookies.
4. How we use your data and our lawful basis
UK data protection law requires us to have a lawful basis for each way we use personal data. We use your data:
- To respond to your enquiry and arrange a data risk assessment or ROT assessment. Lawful basis: our legitimate interests in responding to business enquiries, or taking steps at your request before entering into a contract.
- To deliver services to clients and manage our relationship. Lawful basis: performance of a contract and our legitimate interests in running our business.
- To send you updates and marketing about our services where you or your organisation have engaged with us, in line with the Privacy and Electronic Communications Regulations. Every email includes a simple way to unsubscribe, and you can opt out at any time. Lawful basis: legitimate interests. If you are a sole trader or partnership, we only send marketing emails with your consent or where you are an existing customer.
- To measure and improve our website using Google Analytics, as described above. Lawful basis: your consent, which you give through the cookie banner and can withdraw at any time.
- To meet legal and regulatory obligations, such as keeping business records. Lawful basis: legal obligation.
Where we rely on legitimate interests, we have considered your rights and expectations and are satisfied they are not overridden.
5. Who we share your data with
We do not sell your personal data. We share it only where necessary with:
- Service providers who help us run our business, namely Microsoft (email and productivity) and our website hosting provider, TMCC Marketing (tmccmarketing.co.uk). They act on our instructions and must keep your data secure.
- Technology partners: depending on the platform chosen for your engagement, we share relevant customer information with BigID or Varonis, for example to register the engagement, license the software and obtain technical support. They use it in line with their own privacy notices.
- Google, which provides Google Analytics and processes website usage data on our behalf, under Google’s data processing terms.
- Professional advisers, such as accountants and lawyers, and authorities where the law requires it.
6. International transfers
Some of our service providers and technology partners, including BigID, Varonis and Google, may process data outside the UK, including in the United States. Where this happens, we make sure appropriate safeguards are in place, such as UK adequacy regulations or the UK International Data Transfer Agreement or Addendum.
7. How long we keep your data
- Enquiries that do not become a client relationship: up to 2 years from our last contact.
- Client and contract records: for the length of the relationship and up to 6 years afterwards, to meet legal, tax and accounting requirements.
- Website analytics data: kept by Google Analytics for the retention period set in our account, after which it is deleted automatically.
- Marketing preferences: until you opt out. We keep a record of your opt-out so we respect it.
When data is no longer needed, we securely delete or anonymise it. Practising what we preach, our own retention is managed by policy.
8. How we protect your data
We are a data security specialist and apply appropriate technical and organisational measures to protect personal data, including access controls, encryption and regular review of who can access what.
9. Your rights
Under UK data protection law you have the right to:
- access the personal data we hold about you
- have inaccurate data corrected
- have your data erased in certain circumstances
- restrict or object to how we use your data, including objecting to direct marketing at any time
- data portability in certain circumstances
- withdraw consent where we rely on it
To use any of these rights, contact our Data Protection Officer using the details above. We will respond within one month, and there is usually no charge.
10. Complaints
If you are unhappy with how we have handled your personal data, please contact our Data Protection Officer first so we can try to put it right.
You also have the right to complain to the Information Commissioner's Office (ICO), the UK regulator for data protection: ico.org.uk/make-a-complaint or 0303 123 1113.
11. Changes to this policy
We may update this policy from time to time. The latest version will always be on this page, with the date it was last updated.